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Privacy Policy

updated 15th December 2025

ATTENTION: IMPORTANT LEGAL NOTICE

Introduction
Please read the following Privacy Policy carefully to understand how we use and protect the information that you provide to us.
By using www.focus-grow-progress.com (“Site”) you consent to the collection, use and transfer of your information under the terms of this Privacy Policy.
This notice is issued by Focus Grow Progress Limited, owned and operated by Mr Jeff Brades, (“we”, “us”, “our”) and we are committed to protecting and respecting your privacy.
This Privacy Policy together with our Terms of Use and any other documents referred to on our Site) sets out the basis on which your personal data will be processed by us.
For the purpose of the Data Protection Act 1998 (the “Act”), and the General Data Protection Regulation (“GDPR”) the data controller is Mr Jeff Brades. 
We may make changes to our Privacy Policy from time to time and when we change the policy in a material way [a notice will be posted on our Site along with the updated Privacy Policy.
You are not required to provide the personal information that we request, but, if you choose not to do so, it may not be possible for us to provide the level of service that you would otherwise receive.

1. Information we may collect from you
1.1. Information collected directly from you

1.We may collect the following information directly from you, at the point at which you register for an event, webinar or cohort: 

(a) Your name, e-mail address; and
 
(b) Information that you provide by engaging in forums on the website, by filling in forms on www.focus-grow-progress.com; or by corresponding with us by e-mail or otherwise, for instance, through surveys.
2. We may also collect information when you:
(a) report a problem with the Site; 

(b) register to use the Site; 

(c) enter a competition, promotion, or survey; or

(d) participate in discussion boards or other social media functions on the Site.
1.2 Information collected automatically

We may collect some information automatically and store it in log files. This information includes Internet Protocol (“IP”) addresses, browser type and language, Internet Service Provider (“ISP”), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.
We use this information to understand and analyse trends, to administer the Site, to learn about, subscribers’, users’, visitors’, members’ or guests’ (“Visitor”) behaviour on the Site, to improve our product and services, and to gather demographic information about our Visitors as a whole.
1.3 Information collected via Third Parties
We may collect the information via trusted third parties who provide services to you through different websites we operate or other services we provide including business partners, sub-contractors, advertising networks, analytics providers, search information providers, and website, hosting and maintenance providers.

2. Cookies

2.1. Our Site uses cookies to distinguish you from other Visitors to our Site. This helps us to provide a better experience when you browse our Site and also allows us to make improvements. 
2.2. Unless otherwise indicated, the Site does not store any information that would, on its own, allow us to identify Visitors without their permission. Any cookies that may be used by this Site are used either solely on a per session basis or to maintain Visitor preferences. Cookies are not shared with any third parties.
2.3. If you wish to disable cookies, you may do so through your individual browser options. More detailed information about cookie management with specific web browsers can be found at the browsers’ respective websites.


3. Uses made of the information
3.1. We use information held about you in the following ways:

3.1.1 to manage any registered accounts that you hold with us;

3.1.2 to verify your identity; 

3.1.3. to ensure that content from our Site is presented in the most effective manner for you and for your computer and as part of our efforts to keep our Site safe and secure;
3.1.4. to administer our Site; 
3.1.5. to carry out internal operations, including troubleshooting, data and statistical analysis, testing and research;
3.1.6. to monitor and understand the interests and preferences of fans of participants in the Focus Grow Progress programme;
3.1.7. to allow you to participate in interactive features of our service, when you choose to do so;
3.1.8. to notify you about changes to our service; and
3.1.9. where we have a legal duty to use or disclose your information (for example, in relation to an investigation by a public authority or in a legal dispute).

4. Legal basis for us processing your personal data
4.1 General 
In general, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to you via email. 
You have the right to withdraw consent at any time and where consent is the only legal basis for processing, we will cease to process data after your consent is withdrawn.
4.1.1. We collect and use your personal data because it is necessary for:
(a) complying with our legal obligations; or

(b) the pursuit of our legitimate interests including but not limited to:

(c) supplying services to you;

(d) protecting Visitors, employees and other individuals and maintaining their safety, health and welfare;
(e) understanding our Visitors’ behaviour, activities, preferences, and needs;
(f) improving existing services and developing new ones;
(g) complying with our legal and regulatory obligations;

(h) preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
(i) handling Visitor contacts, queries, complaints or disputes;

(j) protecting us, our employees and Visitors, by taking appropriate legal action against third parties who have committed criminal acts, or are in breach of legal obligations to us;
(k) effectively handling any legal claims or regulatory enforcement actions taken against us;
(l) training our employees in respect of providing services to Visitors. 

5. Disclosure of your information to third parties
5.1. Service Providers
1. In order to make certain services available to you, we may need now or in the future to share your personal data with members of our group and some of our service partners including:
(a) advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
(b) analytics and search engine providers that assist us in the improvement and optimisation of our Site;
5.2. Other Third Parties
5.2.1 Aside from our service providers, we will not disclose your personal data to any third party, except as set out below and we will never sell or rent your data to other organisations for marketing purposes.
5.2.2 We may, however, share your data with:
(a) prospective sellers or buyers, in the event that we sell or buy any business or assets, in which case we may need to disclose your personal data to a prospective buyer or seller; and
(b) prospective third parties which acquire our assets, in the event that we are acquired by a third party, in which case personal data we hold will be transferred to the third party acquiring our other assets.
(c) Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers:
(d) in order to enforce or apply our terms of website use or terms and conditions of sale and other agreements;
(e) to protect the rights, property, or safety of, our Visitors, or others (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; or
(f) where we are required to do so to comply with our legal obligations, to exercise our legal rights (for example in court cases), for the prevention, detection, investigation of crime or prosecution of offenders; and for the protection of our employees and Visitors.

6. Where we store your personal data
6.1. The personal data that we collect from you may be transferred to, and stored at a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7. How we protect your data
7.1. We are committed to keeping your personal data safe and secure. 
1. Our security measures include: 
(a) encryption of data;
(b) regular cyber security assessments of all service providers who may handle your personal data;
(c) regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;
(d) monthly penetration testing of systems; and
(e) security controls which protect our entire infrastructure from external attack and unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.

8. Duration of storage
8.1. We will not retain your data for longer than necessary for the purposes set out in this policy unless a longer retention period is required or permitted by law.

9. Links to other Websites

9.1. Our Site may contain links to third party websites, and some of our services provide you with access to third party services (such as social networks).

9.2. We have no control over how third-party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third-party websites and services or their privacy practices. Please read the privacy statements of any third-party websites or services that you access from our websites or services.

10. Your rights
10.1. The rights that you have in your personal data are due to be expanded significantly after a new law, the GDPR, comes into force on 25 May 2018. 
10.2. We are committed to handling your personal data in the right way and we welcome the new rights introduced; your enhanced rights as from 25 May 2018 are set out below:
10.2.1. You may opt out of any marketing communications that we send you, even after initially consenting.
10.2.2. Your information will be treated securely and strictly in accordance with the Data Protection Act 1998 (and the GDPR, when it comes into force).  

10.2.3. You have the right to access information held about you. Any access request may be subject to a fee specified by law (currently of £10.00). After 25 May 2018, we will not charge a standard administrative fee of £10.00 but please note we may still be able to recover costs from you where your request is vexatious or very repetitive in nature.
10.2.4. You have the right to ask us (at no cost) to update and correct any personal information which is out of date or incorrect. 
10.2.5. You have the right to ask us to erase your personal data or restrict our processing of the data if you wish. 
10.2.6. Where you have consented to our processing your data in a certain manner, you have the right to withdraw that consent at any time. 
10.2.7. You have the right to make a complaint directly with the Information Commissioner’s Office (“ICO”). In order to report a concern, you should follow the directions given on www.ico.org.uk which contains details about available methods of complaint.   
10.2.8. You have the right to receive from us a copy of the personal data in a commonly used, machine readable format and the right to store it for further personal use on a private device.
You have the right to transmit the personal data to another entity where this is technically possible. 
You can help ensure that your contact information and communication preferences are accurate, complete, and up to date by contacting us via the Contact Us page. 
If you want to learn more about the rights you have in respect of your personal data, you should visit the ICO’s website at www.ico.gov.uk.

11. Contact
If you have any questions about this Privacy Policy or the practices of this site, please contact us at tellmemore@focus-grow-progress.com 

TERMS OF SERVICE
Binding Arbitration (“Arbitration Agreement”)
a. Applicability of Arbitration Agreement. You agree that any dispute or claim against us, or our vendors or service providers(collectively, “We” or “Us”), related in any way to your access or use of this website, to these Terms, or to any aspect of your relationship with Us, will be resolved by binding arbitration, rather than in court, except that (1) you may assert claims in small claims court if your claims qualify, so long as the matter remains in such court and advances only on an individual (non-class, non-representative) basis; and (2) you or We may seek equitable relief in court for infringement or other misuse of intellectual property rights (such as trademarks, trade dress, domain names, trade secrets, copyrights, and patents). You agree that you must commence any arbitration or other claim within one (1) year after the dispute arises; otherwise, the claim is permanently barred, which means that you will no longer have the right to assert a claim regarding the dispute. This Arbitration Agreement will apply, without limitation, to all claims that arose or were asserted before the effective date of these Terms or any prior version of this Arbitration Agreement.

You agree in advance that you will not participate in or seek to recover monetary or other relief in any lawsuit filed against Us, alleging class, collective, and/or representative claims on your behalf. Instead, by agreeing to arbitration, you may bring your claims against any of Us in an individual arbitration proceeding (except for any Batch Arbitration, as described below). If successful on such claims, you could be awarded money or other relief by an arbitrator. You acknowledge that you have been advised that you may consult with an attorney in deciding whether to accept these Terms, including this Arbitration Agreement.

The Arbitration Act 2025 governs the interpretation and enforcement of this Arbitration Agreement.
b. Process. To begin a claim, you must first send a letter describing your claim in detail, including your name and contact information, your legal claim, the specific facts giving rise to your claim (including the date(s) and amount(s) of any relevant transaction or interaction with us), and the requested relief, to support@dcfcfans.uk. You and We agree to attempt in good faith to negotiate an informal resolution of your claim. If a resolution is not reached within thirty (30) days, you may commence an arbitration action as set forth herein. The arbitration will be conducted by LCIA an established alternative dispute resolution provider. Disputes involving claims and counterclaims under £250,000, not inclusive of attorneys’ fees and interest, will be subject to LCIA most current version of the Arbitration Rules and procedures available at https://www.lcia.org/Dispute_Resolution_Services/lcia-arbitration-rules-2020.aspx all other claims will be subject to LCIA most current version of the Comprehensive Arbitration Rules and Procedures, available at https://www.lcia.org/Dispute_Resolution_Services/lcia-arbitration-rules-2020.aspx LCIA rules are also available at https://www.lcia.org or by calling LCIA at +44 (0) 20 7936 6200. If LCIA is not available to arbitrate, the parties will select an alternative arbitral forum. You may choose to have the arbitration conducted remotely, based on written submissions, or in person at a mutually agreed location. We will be entitled to make an offer of judgment in the arbitration proceeding. If the offer of judgment is not accepted, and the award is not more favourable than the unaccepted offer, you will be solely responsible for all costs incurred by Us after the offer of judgment is made to the extent permitted by applicable law. Any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction.

c. Fees. If the arbitrator finds that you cannot afford to pay LCIA filing, administrative, hearing, and/or other fees, and you cannot obtain a waiver from LCIA, we will pay them for you. If the arbitrator determines the claims are frivolous, you agree to pay Us our legal fees and costs in the arbitration, to the extent permitted by applicable law.

d. Authority of Arbitrator. The arbitrator, and not any court or agency, will have exclusive authority to resolve any dispute related to the interpretation, applicability, enforceability, or formation of this Arbitration Agreement, including, but not limited to, any claim that all or any part of this Arbitration Agreement is void or voidable. The arbitration will decide the rights and liabilities, if any, of you and Us. The arbitration proceeding will not be consolidated with any other matters or joined with any other cases or parties. The arbitrator will have the authority to grant motions dispositive of all or part of any claim. The arbitrator will have the authority to award monetary damages and to grant any non-monetary remedy or relief available to an individual under applicable law, the arbitral forum’s rules, and these Terms (including the Arbitration Agreement). The arbitrator will issue a written award and statement of decision describing the essential findings and conclusions on which the award is based, including the calculation of any damages awarded. The arbitrator has the same authority to award relief on an individual basis that a judge in a court of law would have. The award of the arbitrator is final and binding upon you and Us.

e. Waiver of Jury Trial. You and We hereby waive any constitutional and statutory rights to sue in court and have a trial in front of a judge or a jury. You and We are instead electing that all claims and disputes will be resolved by arbitration under this Arbitration Agreement, except as specified in Section (a) above. An arbitrator can award on an individual basis the same damages and relief as a court and must follow this Agreement as a court would. However, there is no judge or jury in arbitration, and court review of an arbitration award is subject to very limited review.

f. Waiver of Class or Consolidated Actions. Except with respect to Batch Arbitration (as defined below), all claims and disputes within the scope of this Arbitration Agreement must be arbitrated on an individual basis and not on a class basis, only individual relief is available, and claims of more than one customer or user cannot be arbitrated or consolidated with those of any other customer or user. In the event that this subparagraph is deemed invalid or unenforceable neither you nor We are entitled to arbitration and instead claims and disputes will be resolved in a court as set forth in these Terms.
g. Batch Arbitration. You and We agree that, in the event that there are fifty (50) or more individual requests for arbitration of a similar nature filed against Us within an approximately (30) thirty-day period (or otherwise in close proximity) regardless of the state(s) in which such claims are filed, LCIA will administer all such similarly situated arbitration demands on a collective basis as a single, consolidated arbitration (subject to a single set of fees, proceeding schedule, and, if required, hearing) before a single arbitrator in accordance with the requirements outlined elsewhere in this section, provided that – in the event that the arbitrator deems it impracticable or inequitable to administer all such claims collectively in a single arbitration – (s)he may group demands for arbitration into groups of not fewer than twenty (20) matters, plus a remainder group as needed (or as otherwise deemed by the arbitrator to be practicable, equitable, and in best keeping with the spirit of this provision) and arbitrate each group of matters as a single, consolidated arbitration (either structure a “Batch Arbitration”). You and We agree (1) to work with LCIA in good faith to facilitate the resolution of disputes on a Batch Arbitration basis and (2) that requests for arbitration are of a “similar nature” if they arise out of the same event, agreement, or factual scenario and raise the same or similar legal issues and seek the same or similar relief. Disagreements over the applicability of this Batch Arbitration process will be settled in a single, consolidated arbitration proceeding that includes all affected parties and is resolved by a single arbitrator subject to the requirements of this section. This Batch Arbitration provision shall in no way be interpreted as authorizing a class or collective arbitration or action of any kind, or any suit or arbitration involving joint or consolidated claims, under any circumstances other than those expressly set forth in this section.

h. Severability. If any part or parts of this Arbitration Agreement are found under the law to be invalid or unenforceable, then such specific part or parts will be of no force and effect and will be severed, and the remainder of the Arbitration Agreement will continue in full force and effect.

i. Survival. This Arbitration Agreement will survive the termination of your relationship with Us.

j. Modification. Notwithstanding any provision in these Terms to the contrary, We agree that if We make any future material change to this Arbitration Agreement, it will not apply to any individual claim(s) for which that you had already provided notice to Us.
Consent to Data Collection.  These Terms of Service incorporate our Privacy Policy above, which discloses how we, our vendors, and our service providers collect and use data when you use the Site and/or mobile applications.  You hereby consent to the collection and use of data by us, our vendors, and our service providers as described in the Privacy Policy (including any links to other policies therein).  You can revoke this consent at any time by following the opt-out instructions in the Privacy Policy or clicking the provided links on the Site.  

Limitations on Liability. YOU UNDERSTAND AND AGREE THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE, OR OUR VENDORS OR SERVICE PROVIDERS (COLLECTIVELY, “WE” OR “US”), SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS OR REVENUES, WHETHER INCURRED DIRECTLY OR INDIRECTLY, OR ANY LOSS OF DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES, RESULTING FROM YOUR ACCESS TO OR USE OF OR INABILITY TO ACCESS OR USE THE WEBSITE.  IN NO EVENT SHALL THE AGGREGATE LIABILITY OF ANY OF US EXCEED ONE HUNDRED U.S. DOLLARS ($100). THE LIMITATIONS OF THIS SUBSECTION SHALL APPLY TO ANY THEORY OF LIABILITY, WHETHER BASED ON WARRANTY, CONTRACT, STATUTE, TORT, OR OTHERWISE, AND WHETHER OR NOT THE PARTIES HAVE BEEN INFORMED OF THE POSSIBILITY OF ANY SUCH DAMAGE, AND EVEN IF A REMEDY SET FORTH HEREIN IS FOUND TO HAVE FAILED ITS ESSENTIAL PURPOSE. 

Third Parties

Google Analytics
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this website, to prepare reports on its activities and share them with other Google services.
Google Analytics Privacy Policy

Spam Defense
The IPS Spam Defense Service passes the email address and IP address of the registering member to the service to determine the likelihood a registering account is a spam source.
Spam Defense Privacy Policy